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Anti-Avoidance Controlled Foreign Corporations

Davies Ward Phillips & Vineberg LLP

Canada Releases Revised Draft Legislation on New Interest Deductibility Rules

The Department of Finance (Canada) (Finance) has released revised draft legislation on the proposed rules regarding excessive interest and financing expenses limitation (EIFEL). The revised draft legislation, released on...more

White & Case LLP

ATAD III: Is the tide turning on shell companies?

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The European Commission (the "Commission") published a draft Directive on 22 December 2021, known as the anti-tax avoidance Directive III ("ATAD III"), aimed at preventing the use of shell companies for tax evasion and...more

Freeman Law

International Tax Treaty: China

Freeman Law on

Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

White & Case LLP

Mexico 2020 Tax Reforms

White & Case LLP on

The Mexican Congress approved with some adjustments the Tax Bill presented by the President on September 8, 2019, that included a proposal of Decree through which various provisions of the Income Tax Law, the Value Added Tax...more

Proskauer Rose LLP

UK Tax Round Up - March 2019

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EU developments - European Court rules that withholding tax exemptions under EU Directives can be denied by abuse of rights principle - At the end of February, the Court of Justice of the European Union (CJEU) issued...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2018 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more

A&O Shearman

The European Commission Investigates U.K. Tax Rules

A&O Shearman on

On October 26, 2017, the European Commission (EC) announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group...more

Alston & Bird

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

Alston & Bird on

On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more

Eversheds Sutherland (US) LLP

Transition tax - enough about how it works; here is what doesn’t work

The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more

Skadden, Arps, Slate, Meagher & Flom LLP

European Commission Opens State Aid Investigation Into Finance Company Exemption From UK CFC Rules

On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more

Hogan Lovells

Draft tax legislation for 2017 released

Hogan Lovells on

Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

Alston & Bird

Treasury Issues Final Regulations Under Section 956

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On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more

Proskauer - Tax Talks

EU Council Agrees on Final Anti Tax Avoidance Directive

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We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

McDermott Will & Emery

Treasury and IRS Issue New Temporary Treasury Regulations

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

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